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Financial Services Law Insights and Observations

FinCEN seeks public comment for changing SSN requirements during customer identification

Agency Rule-Making & Guidance Customer Identification Program FinCEN Anti-Money Laundering

Agency Rule-Making & Guidance

On March 29, FinCEN published a request for information (RFI) and comment in the Federal Register, in consultation with the OCC, FDIC, NCUA, and the Fed, to receive more information on the Customer Identification Program (CIP) Rule requirement. This announcement extended the comment period as the regulators explored how banks can better collect a customer’s social security number (SSN). Specifically, FinCEN sought information on the “potential risks and benefits” if banks were to be allowed to collect partial SSNs from customers, and then used a “reputable” third-party source to obtain the full SSN. FinCEN noted there has been “expressed interest” in permitting this practice. Written comments must be received on or before May 28.